https://www.taxtmi.com/caselaws?id=304386 The appeal was partly allowed by the Tribunal. It directed the exclusion of Infosys BPM Ltd. and Eclerx Services Ltd. from the list of comparables due to functional differences. The Tribunal remitted the comparability of Sundaram Business Services Ltd. and ACE Software Exports Ltd. to the AO/TPO for further consideration. It upheld the re-characterization of trade receivables as unsecured loans, directing the computation of notional interest using LIBOR + 2%. Other grounds raised in the appeal were dismissed, including the application of various filters and adjustments related to transfer pricing. en-us Fri, 21 Jan 2022 00:00:00 +0530 Fri, 01 Dec 2023 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304386 The appeal was partly allowed by the Tribunal. It directed the exclusion of Infosys BPM Ltd. and Eclerx Services Ltd. from the list of comparables due to functional differences. The Tribunal remitted the comparability of Sundaram Business Services Ltd. and ACE Software Exports Ltd. to the AO/TPO for further consideration. It upheld the re-characterization of trade receivables as unsecured loans, directing the computation of notional interest using LIBOR + 2%. Other grounds raised in the appeal were dismissed, including the application of various filters and adjustments related to transfer pricing. Case-Laws Income Tax Fri, 21 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304386